Monday, February 24, 2014

What's in a Label? Undefined Whiskey Terms

The US regulations governing whiskey include definitions of many terms that appear on labels, including straight, bottled in bond and blended. While there are long lists of defined terms, there are some common label terms that are not defined. It's important to know what these are because when a term is undefined, it means that it could be used very loosely. Here is a list of some common whiskey terms that are not defined in the regulations.

Barrel Proof/Cask Strength: The general understanding of this term among consumers is that the whiskey has not been diluted with water, but does it always mean that? Can a small amount of water be added to keep batches consistent? If a label said "no added water," that would be a definitive factual statement that you could take to the bank, but "barrel proof" or "cask strength" are a bit more fuzzy. This isn't to suggest that anyone is actually adding water to barrel proof whiskey, but it is not a defined term.

Moonshine: Traditionally, moonshine meant any illegally made alcohol. Obviously, when it appears on a label, it doesn't mean that. These days, it seems to be used for unaged spirits, both whiskey and sugar based, but it's not defined, so it really has no meaning.

Single Barrel: Most of us think this means that the the whiskey in the bottle is the product of one barrel, but does that mean only one barrel? The My Annoying Opinions blog recently did an excellent report about how, in Scotch, single barrel whiskeys are sometimes rebarreled (thus not literally aging entirely in a single barrel), but it could go even further. If a company vatted a number of barrels and then rebarreled them, presumably they could still use the single barrel designation once they bottled those barrels. I have heard rumors of this practice occurring in American whiskey, and it is contrary to what most educated whiskey consumers expect from a single barrel whiskey.

Single Malt: In Scotland, a single malt is a whisky that was (1) distilled at a single distillery and (2) made from 100% malted barley. In the US, this term has no legal meaning. While we all assume that American whiskeys labeled as single malt adhere to the same definition as Scotch, there is no regulation to ensure that is the case.

Small Batch: Small batch is a meaningless marketing term. If Jim Beam, the world's largest bourbon company, can call its bourbons "small batch," then who can't?

White Whiskey: This is another term that has come into frequent use fairly recently but has no legal definition. We all know white whiskey means unaged whiskey, but unless it's corn whiskey, it still has to spend some time in wood to be called whiskey. As a result, lots of white whiskeys get dumped into a barrel and then immediately dumped out, a silly practice that is required by the current definitions.

These terms are so common that it would be helpful if the TTB issued regulations defining them. With the exception of small batch, there is a pretty common understanding among consumers of what these terms mean, and it would be good to know that those understandings are correct and are being adhered to by the industry.

10 comments:

Thanks for putting this out there. An important post. The games around "Single Barrel" and "Small Batch", in particular, are potentially explosive. Remember when Russell's Reserve came out with their "Small Batch Single Barrel" last year? It turns out they may have been literally telling the truth!

"FINSHED IN" AND "FINISHED WITH" are favorites of mine. Frequently zero factual information defining what "finished in X" means to a product. Then you have products like last year's Jim Beam Signature Craft "Finished With Rare Spanish Brandy" which had more than a few bourbon fans tripped-up at release.I'm not saying Beam was trying to mislead anyone, but when people hear "finshed with" the mind leaps to cask types, not liters of Brandy de Jerez.

VT Mike, the issue with the terms above is that because they are undefined, the terms don't have a concrete meaning. However, the regulations do prohibit putting any false statement on a label. Unlike the terms above, 100% rye is clear and unambiguous such that if it were false, it would violate that prohibition...if anyone found out.

What about terms like "Black Maple Hill" or "Basil Hayden?" They shouldn't use fictitious places or names on the label either. There is no bourbon from black maple hill and nobody named Basil Hayden ever made any bourbon. The TTC should get on that.

It would seem that if you wanted consistency in your "barrel strength" whiskey, you would just mix all of the barrels together before bottling, not add water. And if you're doing "single barrel barrel strength," then it should be understood that there will be some variations, not only in alcohol content, but flavor.